Job No.: TCS00694/13

 

 

 

 

 

 

 

 

 

Agreement No. CE 45/2008 (CE)

Liantang/Heung Yuen Wai

Boundary Control Point and Associated Works

 

 

 

 

 

 

 

 

 

Monthly Environmental Monitoring and Audit Report (No.51) – October 2017

 

 

 

 

 

 

 

 

Prepared For

 

 

 

 

Civil Engineering and Development Department (CEDD)

 

 

 

 

 

 

 

 

 

 

 

Date

Reference No.

Prepared By

Certified By

13 November 2017

TCS00694/13/600/R1307v2

Nicola Hon

 (Environmental Consultant)

Tam Tak Wing

(Environmental Team Leader)

 

Version

Date

Remarks

1

9 November 2017

First Submission

2

13 November 2017

Amended according to the IEC’s comments on 10 November 2017

 

 

 

 

 

 


 

 

 

 

executive summary

ES01            This is the 51st monthly EM&A report presenting the monitoring results and inspection findings for the reporting period from 1 to 31 October 2017 (hereinafter ‘the Reporting Period’).

 

Environmental Monitoring and Audit Activities

ES02            To facilitate the project management and implementation, Liantang/Heung Yuen Wai Boundary Control Point and Associated Works of the Project is divided to seven CEDD contracts including Contract 2 (CV/2012/08), Contract 3 (CV/2012/09), Contract 4 (NE/2014/02), Contract 5 (CV/2013/03), Contract 6 (CV/2013/08) and Contract 7 (NE/2014/03) and an ArshSD contract (Contract SS C505).

 

ES03            In the Reporting Period, the major construction works under Liantang/Heung Yuen Wai Boundary Control Point and Associated Works of the Project included Contract 2, Contract 3, Contract 4, Contract 6, Contract 7 and Contract SS C505.  Environmental monitoring activities under the EM&A programme in the Reporting Period are summarized in the following table.

 

Environmental Aspect

Environmental Monitoring Parameters / Inspection

Reporting Period

Number of Monitoring Locations to undertake

Total Occasions 

Air Quality

1-hour TSP

9

135

24-hour TSP

9

45

Construction Noise

Leq(30min) Daytime

10

45

Water Quality

Water in-situ measurement and/or sampling

WM1 & WM1-C

13 Scheduled & 1 extra

WM2A(a) & WM2A-Cx

13 Scheduled & 3 extra

WM2B & WM2B-C

(*) 13 Scheduled

WM3x &WM3-C

13 Scheduled & 0 extra

WM4, WM4-CA &WM4-CB

13 Scheduled & 2 extra

Ecology

Woodland compensation

i)     General Health condition of planted species

ii)   Survival of planted species

9 Quadrats

0

Joint Site Inspection / Audit

IEC, ET, the Contractor and RE joint site Environmental Inspection and Auditing

Contract 2

4

Contract 3

4

Contract 4

4

Contract 6

4

Contract 7

4

Contract SS C505 (#)

4

Note: Extra monitoring day was due to measurement results exceedance

(#) IEC only joined one (1) event of site inspection for Contract SS C505.

(*) Water sampling was unable to carry out at WM2B and WM2B-C due to shallow water (water depth under 150mm)

 

Action and Limit (A/L) Levels exceedance

ES04            In the Reporting Period, no air quality and construction noise exceedance and valid noise complaint were recorded.  For water quality monitoring, a total of eleven (11) Action level/ Limit Level exceedances were recorded under the Project.  The summary of exceedance in the Reporting Period is shown below.

 

Environmental Aspect

Monitoring Parameters

Action Level

Limit Level

Event & Action

NOE Issued

Investigation Result

Project related exceedance

Corrective Actions

Air Quality

1-hour TSP

0

0

0

--

--

--

24-hour TSP

0

0

0

--

--

--

Construction Noise

Leq(30min) Daytime

0

0

0

--

--

--

Water Quality

DO

0

0

0

-

--

--

Turbidity

1

4

5

-  All exceedances were non-project related. 

0

The Contractors were reminded to implement water quality mitigation measure.

SS

0

6

6

0

 

Environmental Complaint

ES05            In this Reporting Period, one (1) documented environmental complaint was received under the EM&A Programme.  Subsequent joint site inspection was carried out for investigation of the complaint and the investigation report revealed that the complaint was not valid to the project.  

Notification of Summons and Successful Prosecutions

ES06            No environmental summons or successful prosecutions were recorded in the Reporting Period. 

Reporting Change

ES07            No reporting changes were made in the Reporting Period.

 

Site Inspection

ES08            In this Reporting Period, joint site inspection to evaluate the site environmental performance at Contract 2 has been carried out by the RE, IEC, ET and the Contractor on 6, 13, 20 and 27 October 2017.  No non-compliance was noted during the site inspection. 

 

ES09            In the Reporting Period, joint site inspection to evaluate the site environmental performance at Contract 3 has been carried out by the RE, IEC, ET and the Contractor on 3, 12, 18 and 26 October 2017.  No non-compliance was noted during the site inspection. 

 

ES10            In the Reporting Period, joint site inspection to evaluate the site environmental performance at Contract 4 has been carried out by the RE, IEC, ET and the Contractor on 6, 13, 16 and 27 October 2017.  No non-compliance was noted.   

 

ES11            In the Reporting Period, joint site inspection to evaluate the site environmental performance at Contract 6 has been carried out by the RE, IEC, ET and the Contractor on 3, 12, 19 and 26 October 2017.  No non-compliance was noted during the site inspection. 

 

ES12            In the Reporting Period, joint site inspection for Contract 7 to evaluate the site environmental performance has been carried out by the RE, IEC, ET and the Contractor on 6, 13, 17 and 27 October 2017.  No non-compliance was noted during the site inspection. 

 

ES13            In the Reporting Period, joint site inspection to evaluate the site environmental performance at Contract SS C505 has been carried out by the RE, ET and the Contractor on 4, 11, 18 and 25 October 2017 in which IEC joined the site inspection on 25 October 2017.  No non-compliance was noted during the site inspection. 

 

 

Future Key Issues

ES14            During dry season, special attention should be paid on the potential construction dust impact since most of the construction sites are adjacent to villages. The Contractor should fully implement the construction dust mitigation measures as appropriately.

 

ES15            Preventive measures for muddy water or other water pollutants from site surface flow to local stream such as Kong Yiu Channel, Ma Wat Channel, Ping Yuen River, Kwan Tei River or public area should be properly maintained.  The Contractors should paid special attention on water quality mitigation measures and fully implement according ISEMM of the EM&A Manual, in particular for working areas near Ma Wat Channel and Ping Yuen River.

 

ES16            In addition, all effluent discharge shall be ensure to fulfill Technical Memorandum of Effluent Discharged into Drainage and Sewerage Systems, inland and Coastal Waters criteria or discharge permits stipulation.

 

ES17            Construction noise would be a key environmental issue during construction work of the Project.  Noise mitigation measures such as using quiet plants should be implemented in accordance with the EM&A requirement.

 

 


Table of Contents

1     Introduction   1

1.1            Project Background   1

1.2            Report Structure  1

2     Project Organization and Construction progress  3

2.1            Construction Contract Packaging   3

2.2            Project Organization   5

2.3            Concurrent Projects  7

2.4            Construction Progress  7

2.5            Summary of Environmental Submissions  9

3     Summary of Impact Monitoring Requirements  13

3.1            General  13

3.2            Monitoring Parameters  13

3.3            Monitoring Locations  13

3.4            Monitoring Frequency and Period   15

3.5            Monitoring Equipment  16

3.6            Monitoring Methodology   18

3.7            Equipment Calibration   20

3.8            Derivation of Action/Limit (A/L) Levels  21

3.9            Data Management and Data QA/QC Control  21

4     Air Quality Monitoring   23

4.1            General  23

4.2            Air Quality Monitoring Results  23

5     Construction Noise Monitoring   26

5.1            General  26

5.2            Noise Monitoring Results (normal daytime) 26

6     Water Quality Monitoring   27

6.1            General  27

6.2            Results of Water Quality Monitoring   27

7     Ecology Monitoring   31

7.1            General  31

8     Waste Management   32

8.1            General Waste Management  32

8.2            Records of Waste Quantities  32

9     Site Inspection   33

9.1            requirements  33

9.2            Findings / Deficiencies During the Reporting Month   33

10   Environmental Complaint and Non-Compliance   37

10.1          Environmental Complaint, Summons and Prosecution   37

11   Implementation Status of Mitigation Measures  40

11.1          General Requirements  40

11.2          Tentative Construction Activities in the Coming Month   40

11.3          Key Issues for the Coming Month   42

12   Conclusions and Recommendations  43

12.1          Conclusions  43

12.2          Recommendations  43

 


List of TABLES

Table 2-1      Status of Environmental Licenses and Permits of the Contracts

Table 3-1        Summary of EM&A Requirements

Table 3-2        Impact Monitoring Stations - Air Quality

Table 3-3        Impact Monitoring Stations - Construction Noise

Table 3-4        Impact Monitoring Stations - Water Quality

Table 3-5        Air Quality Monitoring Equipment

Table 3-6        Construction Noise Monitoring Equipment

Table 3-7        Water Quality Monitoring Equipment

Table 3-8        Action and Limit Levels for Air Quality Monitoring

Table 3-9        Action and Limit Levels for Construction Noise

Table 3-10      Action and Limit Levels for Water Quality

Table 4-1        Summary of 24-hour and 1-hour TSP Monitoring Results – AM1a

Table 4-2        Summary of 24-hour and 1-hour TSP Monitoring Results – AM2

Table 4-3        Summary of 24-hour and 1-hour TSP Monitoring Results – AM3

Table 4-4        Summary of 24-hour and 1-hour TSP Monitoring Results – AM4B

Table 4-5        Summary of 24-hour and 1-hour TSP Monitoring Results – AM5a

Table 4-6        Summary of 24-hour and 1-hour TSP Monitoring Results – AM6

Table 4-7        Summary of 24-hour and 1-hour TSP Monitoring Results – AM7a

Table 4-8        Summary of 24-hour and 1-hour TSP Monitoring Results – AM8

Table 4-9        Summary of 24-hour and 1-hour TSP Monitoring Results – AM9b

Table 5-1        Summary of Construction Noise Monitoring Results

Table 5-2        Summary of Construction Noise Monitoring Results

Table 6-1        Summary of Water Quality Monitoring Results for Contract 2 and 3

Table 6-2        Summary of Water Quality Monitoring Results for Contract 6 and SS C505

Table 6-3        Summary of Water Quality Monitoring Results for Contract 6

Table 6-4        Summary of Water Quality Monitoring Results for Contract 2 and 6

Table 6-5        Action and Limit (A/L) Levels Exceedance Recorded

Table 6-6        Summary of Water Quality Exceedance in the Reporting Period

Table 8-1        Summary of Quantities of Inert C&D Materials

Table 8-2        Summary of Quantities of C&D Wastes

Table 9-1        Site Observations for Contract 2

Table 9-2        Site Observations for Contract 3

Table 9-3        Site Observations for Contract 4

Table 9-4        Site Observations for Contract 5

Table 9-5        Site Observations for Contract 6

Table 9-6        Site Observations for Contract SS C505

Table 10-1      Statistical Summary of Environmental Complaints

Table 10-2      Statistical Summary of Environmental Summons

Table 10-3      Statistical Summary of Environmental Prosecution

Table 11-1      Environmental Mitigation Measures

 

 

 

 

List of Appendices

Appendix A    Layout Plan of the Project

Appendix B    Organization Chart

Appendix C    3-month rolling construction program

Appendix D    Designated Monitoring Locations as Recommended in the Approved EM&A Manual

Appendix E    Monitoring Locations for Impact Monitoring

Appendix F     Calibration Certificate of Monitoring Equipment and HOKLAS-accreditation Certificate of the Testing Laboratory

Appendix G    Event and Action Plan

Appendix H    Impact Monitoring Schedule

Appendix I     Database of Monitoring Result

Appendix J     Graphical Plots for Monitoring Result

Appendix K    Meteorological Data

Appendix L    Waste Flow Table

Appendix M   Implementation Schedule for Environmental Mitigation Measures

Appendix N    Investigation Report for Exceedance

Appendix O    Investigation Report for Complaint

 

 

 


1                    Introduction

1.1              Project Background

1.1.1                 Civil Engineering and Development Department is the Project Proponent and the Permit Holder of Agreement No. CE 45/2008 (CE) Liantang / Heung Yuen Wai Boundary Control Point and Associated Works, which is a Designated Project to be implemented under Environmental Permit number EP-404/2011/D granted on 20 January 2017.

 

1.1.2                 The Project consists of two main components: Construction of a Boundary Control Point (hereinafter referred as “BCP”); and Construction of a connecting road alignment.  Layout plan of the Project is shown in Appendix A.

 

1.1.3                 The proposed BCP is located at the boundary with Shenzhen near the existing Chuk Yuen Village, comprising a main passenger building with passenger and cargo processing facilities and the associated customs, transport and ancillary facilities.  The connecting road alignment consists of six main sections:

1)             Lin Ma Hang to Frontier Closed Area (FCA) Boundary – this section comprises at-grade and viaducts and includes the improvement works at Lin Ma Hang Road;

2)             Ping Yeung to Wo Keng Shan – this section stretches from the Frontier Closed Area Boundary to the tunnel portal at Cheung Shan and comprises at-grade and viaducts including an interchange at Ping Yeung;

3)             North Tunnel – this section comprises the tunnel segment at Cheung Shan and includes a ventilation building at the portals on either end of the tunnel;

4)             Sha Tau Kok Road – this section stretches from the tunnel portal at Wo Keng Shan to the tunnel portal south of Loi Tung and comprises at-grade and viaducts including an interchange at Sha Tau Kok and an administration building;

5)             South Tunnel – this section comprises a tunnel segment that stretches from Loi Tung to Fanling and includes a ventilation building at the portals on either end of the tunnel as well as a ventilation building in the middle of the tunnel near Lau Shui Heung;

6)             Fanling – this section comprises the at-grade, viaducts and interchange connection to the existing Fanling Highway.

 

1.1.4                 Action-United Environmental Services & Consulting has been commissioned as an Independent ET to implement the relevant EM&A program in accordance with the approved EM&A Manual, as well as the associated duties.  As part of the EM&A program, the baseline monitoring has carried out between 13 June 2013 and 12 July 2013 for all parameters including air quality, noise and water quality before construction work commencement.  The Baseline Monitoring Report summarized the key findings and the rationale behind determining a set of Action and Limit Levels (A/L Levels) from the baseline data.  Also, the Project baseline monitoring report which verified by the IEC has been submitted to EPD on 16 July 2013 for endorsement.  The major construction works of the Project was commenced on 16 August 2013 in accordance with the EP Section 5.3 stipulation.

 

1.1.5                 This is 51st monthly EM&A report presenting the monitoring results and inspection findings for reporting period from 1 to 31 October 2017.

 

1.2              Report Structure

1.2.1                 The Monthly Environmental Monitoring and Audit (EM&A) Report is structured into the following sections:-

Section 1         Introduction

Section 2         Project Organization and Construction Progress

Section 3         Summary of Impact Monitoring Requirements

Section 4         Air Quality Monitoring

Section 5         Construction Noise Monitoring

Section 6         Water Quality Monitoring

Section 7         Ecology Monitoring

Section 8         Waste Management

Section 9         Site Inspections

Section 10       Environmental Complaints and Non-Compliance

Section 11       Implementation Status of Mitigation Measures

Section 12       Conclusions and Recommendations

 

 

 


2                    Project Organization and Construction progress

2.1              Construction Contract Packaging

2.1.1                 To facilitate the project management and implementation, the Project would be divided by the following contracts:

·              Contract 2 (CV/2012/08)

·              Contract 3 (CV/2012/09)

·              Contract 4 (NE/2014/02)

·              Contract 5 (CV/2013/03)

·              Contract 6 (CV/2013/08)

·              Contract 7 (NE/2014/03)

·              ArchSD Contract No. SS C505

 

2.1.2                 The details of each contracts is summarized below and the delineation of each contracts is shown in Appendix A.

 

Contract 2 (CV/2012/08)

2.1.3                 Contract 2 has awarded in December 2013 and construction work was commenced on 19 May 2014.  Major Scope of Work of the Contract 2 is listed below:

·                construction of an approximately 5.2km long dual two-lane connecting road (with about 0.4km of at-grade road and 4.8km of tunnel) connecting the Fanling Interchange with the proposed Sha Tau Kok Interchange;

·                construction of a ventilation adit tunnel and the mid-ventilation building;

·                construction of the north and south portal buildings of the Lung Shan Tunnel and their associated slope works;

·                provision and installation of ventilation system, E&M works and building services works for Lung Shan tunnel and Cheung Shan tunnel and their portal buildings;

·                construction of Tunnel Administration Building adjacent to Wo Keng Shan Road and the associated E&M and building services works; and

·                construction of associated footpath, slopes, retaining structures, drainage, sewerage, waterworks, landscaping works and other ancillary works.

 

Contract 3 (CV/2012/09)

2.1.4                 Contract 3 was awarded in July 2013 and construction work was commenced on 5 November 2013.  Major Scope of Work of the Contract 3 is listed below:

·                construction of four link roads connecting the existing Fanling Highway and the south portal of the Lung Shan Tunnel;

·                realignment of the existing Tai Wo Service Road West and Tai Wo Service Road East;

·                widening of the existing Fanling Highway (HyD’s entrustment works);

·                demolishing existing Kiu Tau vehicular bridge and Kiu Tau footbridge and reconstruction of the existing Kiu Tau Footbridge (HyD’s entrustment works); and

·                construction of associated footpath, slopes, retaining structures, drainage, sewerage, waterworks, landscaping works and other ancillary works.

 

Contract 4 (NE/2014/02)

2.1.5                 Contract 4 has awarded in mid-April 2016 and construction work was commenced on 2 May 2017.  The scope of work of the Contract 4 includes:

·                design, supply, delivery, installation, testing and commissioning of a traffic control and surveillance system for the connecting road linking up the Liantang / Heung Yuen Wai Boundary Control Point and the existing Fanling Highway.

 

 

Contract 5 (CV/2013/03)

2.1.6                 Contract 5 has awarded in April 2013 and construction work was commenced in August 2013.  Major Scope of Work of the Contract 5 is listed below:

·                site formation of about 23 hectares of land for the development of the BCP;

·                construction of an approximately 1.6 km long perimeter road at the BCP including a 175m long depressed road;

·                associated diversion/modification works at existing local roads and junctions including Lin Ma Hang Road;

·                construction of pedestrian subway linking the BCP to Lin Ma Hang Road;

·                provision of resite area with supporting infrastructure for reprovisioning of the affected village houses; and

·                construction of associated footpath, slopes, retaining structures, drainage, sewerage, waterworks, landscaping works and other ancillary works.

 

Contract 6 (CV/2013/08)

2.1.7                 Contract 6 has awarded in June 2015 and construction work was commenced on 23 October 2015.  Major Scope of Work of the Contract 6 would be included below:

Ÿ    construction of an approximately 4.6km long dual two-lane connecting road (with about 0.6km of at-grade road, 3.3km of viaduct and 0.7km of tunnel) connecting the BCP with the proposed Sha Tau Kok Road Interchange and the associated ventilation buildings;

Ÿ    associated diversion/modification works at access roads to the resite of Chuk Yuen Village;

Ÿ    provision of sewage collection, treatment and disposal facilities for the BCP and the resite of Chuk Yuen Village;

Ÿ    construction of a pedestrian subway linking the BCP to Lin Ma Hang Road;

Ÿ    provisioning of the affected facilities including Wo Keng Shan Road garden; and

Ÿ    construction of associated footpath, slopes, retaining structures, drainage, sewerage, waterworks, landscaping works and other ancillary works.

 

Contract 7 (NE/2014/03)

2.1.8                 Contract 7 has awarded in December 2015 and the construction works of Contract 7 was commenced on 15 February 2016.  Major Scope of Work of the Contract 7 would be included below:

Ÿ    construction of the Hong Kong Special Administrative Region (HKSAR) portion of four vehicular bridge

Ÿ    construction of one pedestrian bridge crossing Shenzhen (SZ) River (cross boundary bridges)

 

ArchSD Contract No. SS C505

2.1.9                 SS C505 has awarded in July 2015 and construction work was commenced on 1 September 2015.  Major Scope of Work of the SS C505 would be included below:

Ÿ    passenger-related facilities including processing kiosks and examination facilities for private cars and coaches, passenger clearance building and halls, the interior fitting works for the pedestrian bridge crossing Shenzhen River, etc.;

Ÿ    cargo processing facilities including kiosks for clearance of goods vehicles, customs inspection platforms, X-ray building, etc.;

Ÿ    accommodation for the facilities inside of the Government departments providing services in connection with the BCP;

Ÿ    transport-related facilities inside the BCP including road networks, public transport interchange, transport drop-off and pick-up areas, vehicle holding areas and associated road furniture etc;

Ÿ    a public carpark; and

Ÿ    other ancillary facilities such as sewerage and drainage, building services provisions and electronic systems, associated environmental mitigation measure and landscape works.

 

2.2              Project Organization

2.2.1                 The project organization is shown in Appendix B.  The responsibilities of respective parties are:

 

Civil Engineering and Development Department (CEDD)

2.2.2                 CEDD is the Project Proponent and the Permit Holder of the EP of the development of the Project and will assume overall responsibility for the project. An Independent Environmental Checker (IEC) shall be employed by CEDD to audit the results of the EM&A works carried out by the ET.

 

Architectural Services Department (ArchSD)

2.2.3                 ArchSD acts as the works agent for Development Bureau (DEVB), for Contract SS C505 Liantang/ Heung Yuen Wai Boundary Control Point (BCP) – BCP Buildings and Associated Facilities.

 

Environmental Protection Department (EPD)

2.2.4                 EPD is the statutory enforcement body for environmental protection matters in Hong Kong.

 

Ronald Lu & Partners (Hong Kong) Ltd (The Architect)

2.2.5                 Ronald Lu & Partners (Hong Kong) Ltd is appointed by ArchSD as an Architect for Contract SS C505 Liantang/ Heung Yuen Wai Boundary Control Point (BCP) – BCP Buildings and Associated Facilities.  It responsible for overseeing the construction works of Contract SS C505 and for ensuring that the works are undertaken by the Contractor in accordance with the specification and contract requirements. The duties and responsibilities of the Architect with respect to EM&A are:

Ÿ    Monitor the Contractors’ compliance with contract specifications, including the implementation and operation of the environmental mitigation measures and their effectiveness

Ÿ    Monitor Contractors’ and ET’s compliance with the requirements in the Environmental Permit (EP) and EM&A Manual

Ÿ    Facilitate ET’s implementation of the EM&A programme

Ÿ    Participate in joint site inspection by the ET and IEC

Ÿ    Oversee the implementation of the agreed Event / Action Plan in the event of any exceedance

Ÿ    Adhere to the procedures for carrying out complaint investigation

Ÿ    Liaison with DSD, Engineer/Engineer’s Representative, ET, IEC and the Contractor of the “Construction of the DSD’s Regulation of Shenzhen River Stage 4 (RSR 4)” Project discussing regarding the cumulative impact issues.

 

Engineer or Engineers Representative (ER)

2.2.6                 The ER is responsible for overseeing the construction works and for ensuring that the works are undertaken by the Contractor in accordance with the specification and contract requirements. The duties and responsibilities of the ER with respect to EM&A are:

·           Monitor the Contractors’ compliance with contract specifications, including the implementation and operation of the environmental mitigation measures and their effectiveness

·           Monitor Contractors’s, ET’s and IEC’s compliance with the requirements in the Environmental Permit (EP) and EM&A Manual

·           Facilitate ET’s implementation of the EM&A programme

·           Participate in joint site inspection by the ET and IEC

·           Oversee the implementation of the agreed Event / Action Plan in the event of any exceedance

·           Adhere to the procedures for carrying out complaint investigation

·           Liaison with DSD, Engineer/Engineer’s Representative, ET, IEC and the Contractor of the “Construction of the DSD’s Regulaiton of Shenzhen River Stage 4 (RSR 4)” Project discussing regarding the cumulative impact issues.

 

The Contractor(s)

2.2.7                 There will be one contractor for each individual works contract. Once the contractors are appointed, EPD, ET and IEC will be notified the details of the contractor.

2.2.8                 The Contractor for Contracts under CEDD should report to the ER. For ArchSD Contract, the Contractor should report to the Architect or Architect’s Representative (AR). The duties and responsibilities of the Contractor are:

·           Comply with the relevant contract conditions and specifications on environmental protection

·           Employ an Environmental Team (ET) to undertake monitoring, laboratory analysis and reporting of EM &A Facilitate ET’s monitoring and site inspection activities

·           Participate in the site inspections by the ET and IEC, and undertake any corrective actions

·           Provide information / advice to the ET regarding works programme and activities which may contribute to the generation of adverse environmental impacts

·           Submit proposals on mitigation measures in case of exceedances of Action and Limit levels in accordance with the Event / Action Plans

·           Implement measures to reduce impact where Action and Limit levels are exceeded

·